DEA Form 106: Reporting the Loss of Controlled Substances
Stay compliant and protect your facility—learn the steps to properly report and address controlled substance losses.
In the high-stakes environment of ambulatory surgery centers (ASCs) and healthcare facilities, controlled substances are essential tools for patient care. However, these medications also require strict oversight and accountability. When controlled substances go missing (whether through theft, diversion, or loss), prompt and proper reporting is not just a regulatory requirement; it's a critical component of facility security and patient safety.
Understanding Your Reporting Obligations
As a DEA registrant, your facility has a legal obligation to report any significant loss or theft of controlled substances. According to DEA regulations, you must:
Report significant losses or thefts in writing within one business day of discovery
Complete and submit DEA Form 106 (Report of Theft or Loss of Controlled Substances)
Maintain records of all reports and investigations for at least two years
But what exactly constitutes a "significant" loss? The DEA doesn't provide a specific quantity threshold, as significance depends on your facility's size, typical inventory, and the circumstances surrounding the loss. Factors to consider include:
The actual quantity missing
Whether the loss creates an adverse impact on patient care
The likelihood of diversion
Local theft patterns
The potential for public harm
Step-by-Step Guide to Completing DEA Form 106
When you discover a significant loss or theft of controlled substances, follow these steps:
1. Immediate Notification
Call your local DEA field office to report the theft or significant loss
Document this notification with the date, time, and name of the DEA employee contacted
2. Access the Form
Go to the DEA Diversion Control Division website (www.deadiversion.usdoj.gov)
Select "Report Theft/Loss of Controlled Substances" under the "Resources" tab
Log in using your DEA registration number and password
3. Complete All Sections
The form requires specific information about:
Your facility and DEA registration
The circumstances of the loss (theft, in-transit loss, employee pilferage, etc.)
Details about the missing substances (name, form, strength, quantity)
Law enforcement notifications
Corrective actions implemented to prevent future occurrences
4. Submit and Maintain Records
Submit the form electronically through the DEA's website
Print a copy for your records
Keep documentation of the submission and any related investigation reports
Document corrective actions implemented following the incident
Beyond Compliance: Building a Robust Prevention Strategy
Let's face it – while reporting is necessary, none of us want to be in the position of filing that DEA Form 106 in the first place. The good news? With thoughtful systems and a vigilant team, you can significantly reduce your risk. Here's how to strengthen your controlled substance safeguards:
Smarter Inventory Management
The days of simply counting pills twice a year are long behind us. Today's best practices include:
Regular spot checks that go beyond minimum requirements – try weekly audits of your highest-risk medications like fentanyl and hydromorphone
Perpetual inventory systems that track each dose from delivery to administration to waste, creating a continuous chain of custody
The power of two – implementing a witness system for all waste documentation creates accountability and drastically reduces opportunities for diversion
Discrepancy investigation protocols that kick in immediately when counts don't match, rather than waiting for the next shift
Physical and Digital Security That Works
Your security measures should create layers of protection without impeding workflow:
Strategically placed cameras that cover medication storage, preparation areas, and disposal locations without making staff feel constantly surveilled
Modern access controls using biometrics, badge readers, or dual-authentication systems that create audit trails of who accessed controlled areas and when
Waste management solutions that render medications unusable immediately after partial doses are administered
Regular security assessments conducted by someone who can think like a potential diverter
Creating a Culture of Awareness
Your team is your most valuable asset in preventing diversion:
Open conversations about diversion risks that normalize vigilance without creating paranoia
Education on recognizing signs of substance use disorder in colleagues, with an emphasis on getting help rather than punishment
Clear, judgment-free reporting channels for staff who notice concerning behaviors or discrepancies
Support systems for staff members who may be struggling with substance issues themselves
Regular team discussions about new diversion trends and tactics seen in healthcare settings
Documentation That Protects Everyone
In healthcare, if it isn't documented, it didn't happen:
Comprehensive transfer logs that account for every handoff between shifts, departments, or individuals
Detailed waste records that specify exact amounts, witnesses, and disposal methods
Regular compliance reviews that examine documentation patterns and identify potential weak spots
Electronic systems that flag unusual patterns like frequent reports of broken vials or documentation discrepancies
Remember, robust prevention isn't just about regulatory compliance – it's about protecting your patients from potential harm, safeguarding your team members from temptation during vulnerable moments, and preserving the integrity of your facility's reputation in the community.
Supporting Your Team Through Reporting and Prevention
Reporting controlled substance losses can be stressful, particularly when diversion by a colleague is suspected. MedServe understands these challenges and offers resources to help:
Documentation templates for internal investigations
Staff training on diversion prevention
Consulting services for security enhancement
Compliance guidance for DEA requirements
Your Partner in Controlled Substance Compliance
Protecting your patients, your facility, and your team requires vigilance in controlled substance management. When losses occur (and statistics show they happen in even the most careful facilities), prompt, thorough reporting through DEA Form 106 is essential.
By understanding your reporting obligations and implementing robust prevention strategies, you can minimize risks while maintaining full compliance with DEA regulations. Remember: proper handling of controlled substance losses isn't just about checking regulatory boxes; it's about upholding the highest standards of healthcare safety and integrity.
Need assistance with controlled substance compliance? Contact MedServe today for specialized support tailored to ASC and healthcare environments.
